The proliferation of economic sanctions in recent years has raised concerns about overcompliance, a pattern of behaviour in which actors exceed legal requirements in complying with sanctions. More specifically, overcompliance has been defined as “a situation in which a market participant applies sanctions – that is, refrains from an otherwise desirable transaction or activity involving some connection with a sanctioned country or person – beyond what is legally mandated by the relevant regime” (Verdier [2023] 473; Breen [2022] 256; Douhan [2022] para. 17). While overcompliance with multilateral sanctions is possible, most attention to this phenomenon has focused on sanctions imposed outside of the United Nations (UN) Charter regime.
Citation
Pierre-Hugues Verdier, Overcompliance, in Elgar Encyclopedia of International Sanctions, Edward Elgar Publishing, 218–219 (2025).